achieved at the ballot box. Dependent as they are upon the appro-
bation of the voters, elected officials of the executive and legislative
branches have always been responsive (as accurately as it could be
interpreted) to popular sentiment. Nor has the federal judiciary
been far behind. What began as a drift toward centralization, moti-
vated by expansionism on land and sea and the policy of internal
improvements in our time, under pressures of complex social and
economic problems--worldwide as well as internal--is seen as the
march of supergovernment.

Men and women still at work in editorial offices can recall the
standard procedures designed to guard against confrontation in
court under the rules of common-law defamation as modified from
state to state by statute. The man with the green eyeshade labored
under such contradictions as truth is a defense in this state and not
at all or only with limitations in the next. The word alleged (not
exactly without value today) was the magic stone of the police
reporter struggling to keep his job. Any journalist from that back-
ground can view only with benign understanding the confusion
among the justices of the Supreme Court as they attempted, in
response to pressures engendered by New Deal reform, to bring
order out of chaos in the realm of defamation law. The instances of
split decisions, plurality decisions, modification if not reversal of
their own decisions, individual self-contradiction together reflect
not ineptitude but the complexity of the problem and the difficulties
of achieving consensus in a fairly new arena. Moreover it is hearten-
ing to observe how the constitutional system of compromise retains
the relative effectiveness expected of it even in the most rarefied
forum of our governmental system.

Nothing reflects the sincerity of purpose motivating the contenti-
ousness of the individual justices more than the thread of consis-
tency binding together the half century of decisions examined by
Professor Lawhorne than the universal concern of the jurists for
sustaining free and uninhibited discussion of all public issues. The
future, as Professor Lawhorne emphasizes, will bring additional
change. It may be safe to speculate shifts from left to right or right to
left with the moods of the electorate. Yet it will remain a fact that
the work of the Supreme Court of the United States at last has built
the foundation, or even more, for a body of constitutional law to
replace the disorderly mishmash of common and statutory law of

-x-